Dear Editor,
We subscribe to Chris Ram’s observation that the modified Environmental Permit applies only to excess of timelines for “flaring events”. We should like the EPA to clarify the following, especially since the Guyana Government is a signatory to the Escazu Regional Agreement on Access to Information, Public Participation and Justice in Environmental Matters in Latin America and the Caribbean.
1. They are adding an extra 14 days to the timelines contracted with Esso Exploration and Production Guyana Limited (EEPGL) before instituting the fine.
2. How are the 14 days counted? Must they be without a break? E.g., if 13 flaring days are followed by one day of no flaring, but oops something happened and we have to flare again, for say another 13 days before ‘fixing’ the fault, and so on and so forth for who knows how long, do we have 13 + 13 + … = 26 + … days for a fine for (26 – 14 = 12) + … days? Or would we have to start over the count again each time because they have not reached the 14 days to become fined?
3. How are we to know when there is flaring and when there is not? Is there a continuous competent EPA presence on the FPSO?
4. We should like to add that while flaring is a bad word in environmental circles, the worse word for gas is venting. Flaring is supposed to burn the natural gas to carbon dioxide (CO2). But what if the gas were vented or let off into the air without burning? Then it could be delivering methane (CH4) which has 84 times the immediate global warming potential (GWP) of CO2 or 28 times the 100-year CO2 GWP into the atmosphere. Is there a continuous EPA presence on the FPSO, qualified and equipped to detect and measure such emissions? Is it the plan that this unmentionable word should not gain common parlance?
We requested daily information from EEPGL and the Ministry of Natural Resources, copied to the EPA, some time ago. Exxon let the public know that they have to flare because of a bad flash compressor, but there is no answer to our request for pressures and analyses at the various decompression stages that could tell us the quantities involved. So we will have to conclude that the Government, the EPA and Exxon want us, the apparently gullible Guyanese public, to applaud them for straining at the gnats of flaring in excess of an undefined 14 days, while we swallow the camel of unknown venting.
Yours faithfully,
Alfred Bhulai
Transparency Institute Guyana Inc
(TIGI)